I am a career civil servant currently employed at the Clinton-Gore White House's Office
of Administration (OA). I have worked for the Executive Office of President ("EOP")
since 1987. I currently hold the rank of GS-14 and had been both Branch Chief and
Acting Branch Chief for Network Infrastructure. The Network Infrastructure Division
falls under OA's Information Systems and Technology ("IST") division. I am currently a
network specialist in the Network Infrastructure division.

When the Clinton-Gore White House first came to power in 1993, Jim McDonald, who
was then the director of the IST division, and I met with Mike Gill, a political aide to
Vice President Gore who served as his information specialist. At this meeting, we
carefully explained to Mr. Gill the legal requirement that the Office of the Vice President
("OVP") manage its electronic records. We explained that this could be done by OA by
backing up the OVP electronic records on tape and maintaining these back-up tapes for
potential legal proceedings. Mr. Gill did not care about these legal requirements and
essentially told us to get lost, that the Vice President's Office would take care of its own
records. Being in no position to contradict a top political aide to the new Vice President,
we let the matter drop. If our advice had been followed, the year's worth of OVP e-mail
(March, 1998 - April, 1999) that was reported "lost" last week by the Clinton-Gore White
House would still be in existence, as they would have been properly backed up by OA.

In fact, Mr. Gill was nicknamed the "Mad Deleter." This nickname referred to his
propensity to delete electronic records as a method of dealing with computer-related
problems.

Early in the Clinton-Gore Administration, I attended a few Clinton-Gore White House
meetings on the White House Office Database ("WHODB"). I quickly came to the
conclusion, based on those meetings, that what was being requested for the WHODB
appeared to be illegal, in that the project called for the use of taxpayer resources to track
political contributions and other improper information. I made my concerns about this
database known to my supervisors at the time, such as Jim McDonald, who was then head
of IST. As a result of my concerns about the legality of the WHODB, I walled myself off
from it and refused to participate in its development.

I believe, in part because of my concerns about WHODB, that I was retaliated against by
the Clinton-Gore White House. Participating in this retaliation were individuals such as
Charles Benjamin, who was head of the IST division for a time. As part of that
retaliation, I was "idled" for about two years - in other words, made to sit in an office all
day with little or nothing to do.

Shortly after Vincent Foster died in July, 1993, I received a call from Jim McDonald, who
wanted me to meet him outside to go for a ride with him. During that ride, Mr.
McDonald informed me that he had found Vincent Foster's computer in a hallway in the
West Wing. In the wake of the mysterious circumstances surrounding Mr. Foster's death,
Mr. McDonald was extremely upset by his discovery and he told me that he was
concerned that he would be killed because of what he had found. To the best of my
knowledge, this computer is currently wrapped in plastic and stored in a computer parts
"depot" in the New Executive Office Building. As far as I know, this computer was
never turned over to investigators. I was told by a colleague at OA that this computer has
no data on it, though I am not aware if the data ever existed, or if it was simply deleted or
if the computer's entire hard disk was "wiped clean."

In June or July, 1998, I learned about the Project X e-mail from Robert Haas. Haas came
into my office and told me about Project X and the threats of jail made to him by Laura
Crabtree. Based on my experience working with her, I believed that Laura Crabtree was
more than capable of making such threats -- it was perfectly in character for her. Haas
told me he had many e-mails which referred to Monica Lewinsky and that he believed
many other e-mails existed among the Project X e-mail that were responsive to other
"FOIA's" (Freedom of Information Act). Computer personnel in OA used the term
"FOIA" as a short-hand for all types of document search requests, whether they were
subpoenas or document requests from independent counsels, Congress, or Plaintiffs in
this case. In other words, I understood Haas to mean that he believed that the Project X e-mail referred to other Clinton-Gore scandals then under investigation, such as Filegate
and Chinagate.

It was my experience that the ARMS system was inadequate in terms of its search
capabilities and I lobbied within OA repeatedly for upgrades to the ARMS system to
make its searches more thorough and efficient. The ARMS system simply could not (and
does not) do what it is legally required to do -- manage in a word-searchable format
certain computer documents for the EOP. Despite my oft-repeated concerns, OA never
acted on my suggestions.

I swear under penalty of perjury that the foregoing is true and correct.